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PUBLIC HEALTH DIVISIONDrinking Water Services
Level 2 Investigation ReviewSilver Falls 2017
Amy Word, REHSDrinking Water Services
April 19, 2017
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Overview of Presentation
1. Level 2 refresher (who, what, when, where, why & how)
2. Review of Level 2 form used3. System examples4. Questions/discussion
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(Enter) DEPARTMENT (ALL CAPS)(Enter) Division or Office (Mixed Case)
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Revised Total Coliform Rule – adopted 4/1/2016
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(Enter) DEPARTMENT (ALL CAPS)(Enter) Division or Office (Mixed Case)
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Revised Total Coliform Rule – adopted 4/1/2016
NounVerbAdjective
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Investigations and Corrective Action
• Because coliform indicates a potential pathway for contamination into the water system, an investigation is required after confirmed total coliform (or E. coli).
• Two levels of investigation: Level 1 (conducted by a water system operator) and Level 2 (conducted by a regulator)
• EPA refers to these as “Assessments”• If sanitary defect(s) are found, they must be corrected to
prevent future contamination.• The cause of coliform may not always be found.
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Investigation Scope
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o Investigations seek to identify situations that could affect water quality in the distribution system, including:• Atypical events (backflow incident, line breaks, etc.)• Changes in distribution system maintenance or operation
that could have affected water quality• Source water changes or changes/interruptions in
treatment practices• Inadequacies in sample sites, sampling protocol, or
sample processing• Damage to or inadequacies in system facilities
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(Enter) DEPARTMENT (ALL CAPS)(Enter) Division or Office (Mixed Case)
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How do I know if a Level 2 has been triggered? (you are sent an email)
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o The following criteria elevate a detection or detections to a Level 2 investigation:
o E. coli MCL (confirmed with a routine EC+ and TC+ repeat/FC+ repeat or a TC+ routine and FC+ repeat)
o More than one month of multiple TC+ samples (within a rolling 12 month period)
o No repeat samples after a TC/FC+ routine sample and a Level 1 had already been done in the rolling 12 month period
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(Enter) DEPARTMENT (ALL CAPS)(Enter) Division or Office (Mixed Case)
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Is there any reason where a Level 2 is triggered but does not need to be performed?
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o YES!!!!o If triggered due to no repeat samples collected:
o If repeat samples had been collected within the 11 days timeframe after the initial positive and turned in late – OR turned in within the 30 day timeframe to complete the Level 2. Then an onsite Level 2 is not needed.
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Do all triggered investigations count towards a treatment requirement?
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o Not all triggers count!
o The health based triggers (sample results) count, monitoring and reporting trigger (no repeat samples/late) do not get factored in.
o HOWEVER, if you feel differently, please consult with your DWS contact.
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What does it look like online?
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Level 1 Coliform Investigations
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• Conducted by the water system staff• Must be completed within 30 days• Includes a basic examination of the source water,
treatment, distribution system and relevant operational practices
• Covers likely cause, corrective action plan, and schedule for correction.
• Investigation form is available on our website• Reports will be reviewed to ensure the investigation
was adequate and complete.
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Level 1 Coliform Investigation Triggers
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o Level 1 investigations are triggered by the following events:• More than 1 sample is total coliform positive at
systems collecting fewer than 40 samples per month• More than 5% of samples are total coliform positive at
systems collecting 40 or more samples per month• Failure to collect every required repeat sample
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Level 2 Coliform Investigations
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• Conducted by the water system’s regulating agency (DWS, County, or Oregon Dept. of Agriculture)
• A more in-depth examination of the system and its monitoring and operational practices
• Must be completed in 30 dayso Level 2 investigations are triggered by the following
events:• Violation of the MCL for E. coli• Two Level 1 triggers within a 12 month period
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(Enter) DEPARTMENT (ALL CAPS)(Enter) Division or Office (Mixed Case)
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Level 2 Coliform Investigations – the real question…
• Do I have to do a site visit EVERY time for a system that has had multiple assessments triggered…..
• No you do not…. But let’s discuss
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On-site discussion points:
• When was the last time you made a site visit?
• Did you thoroughly look at the system?
• How comfortable are you with the water system’s operator?
Ultimately the decision is yours – you are the ones that know the water system the best.
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How do I document a Level 2 investigation?
• All investigations require follow up. A follow up is documented with the completion of the investigation forms. The forms are then sent in to the compliance email.
• If a Level 2 is decided, by the regulator, to be done over the phone, a Level 2 form still needs to be filled out and submitted. This will then close out the schedule.
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Corrective Action Requirements
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• Sanitary defects must be described on the investigation form.
• Sanitary defects found during an investigation must be corrected and corrective actions described on the investigation form.
• The water system must submit the investigation form to their regulator within 30 days of the investigation trigger.
• The form must indicate a timetable for any corrective actions not already completed.
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System investigation case studies
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UPS-Hermiston
1 well, 1 PT, one connection
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• Distinction of being the first system in the state to trigger a mandatory treatment install.
• System was having a little total coliform issue• 2013 - 1 MCL vio• 2015 – 5 MCL vio• 2016 – 1 MCL and investigations
• Source – single GW well and all triggered samples were total coliform positive.
• Concern had been raised late 2015 due to knowledge of a neighboring well with confirmed contamination and the system will need to start planning.
• UV unit* was approved and installed January 2017
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Black Mountain Water District
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So – what is next for them?
The circuit rider will be making a site visit today (4/19/17). Will await their report and have to see how we all can proceed.
It is a complicated scenario and am hoping one day to be able to have a success story follow up to show. But for now, it’s a wait and see.